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Responses to SCA-TR-2019-PR004,

Revision 0, Dose Reconstruction Template 

Review for the Peek Street Facility, 

Schenectady, New York

Response Paper

National Institute for Occupational 

Safety and Health

June 14, 2022

Mutty M. Sharfi 

Oak Ridge Associated Universities Team

Reviewed by Angelica Gheen

Division of Compensation Analysis and Support

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Response Paper Responses to SCA-TR-2019-PR004, Revision 0, Dose Reconstruction 

Template Review for the Peek Street Facility, Schenectady, New York

June 14, 2022

Page 2 of 8 

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

FINDING 1

"The assumption of 100% 30–250 keV for the penetrating photon energy distribution is 

unsupported and inconsistent with assumptions used in the Hanford technical basis document." 

NIOSH Response:

Given the various source terms at the Peek Street Facility (PSF) described below, NIOSH 

believes that the default assumption of 100% 30–250 keV for the penetrating photon energy is 

not only consistent with current guidance, it is the assumption more favorable to the claimant.

The Peek Street Facility processed natural uranium, enriched uranium, plutonium, encapsulated 

radium, polonium, and even fission products, which can be associated with a variety of photon 

energy distributions. The PSF also had and operated a critical assembly and/or zero-pile reactor. 

Unlike Hanford, the PSF was very small and most of the radiation sources were inside a single 

building (the main building). In most instances, it cannot be determined which radiation 

source(s) a worker was exposed to in that building. Because the bulk of the radioactive material 

at the PSF was natural and enriched uranium, most if not all PSF workers were likely externally 

exposed to uranium during periods of their employment. Table 6-7 in revision 4 of ORAUTTKBS-0006-6, Hanford Site – Occupational External Dose [ORAUT 2010], recommends a 

photon energy distribution assumption of 100% 30–250 keV photons for fuel fabrication 

facilities, which were uranium facilities at Hanford. 

FINDING 2

"The assumption of an uncertainty factor of 1.3 is unsupported and inconsistent with the cited 

reference."

NIOSH Response:

The uncertainty value of 1.3 in the dose reconstruction (DR) Template reflects the uncertainty 

factor that was in revision 03 of ORAUT-TKBS-0006-6 [ORAUT 2007c] (see Section 6.10), 

which has since been revised. NIOSH agrees that revision 04 of ORAUT-TKBS-0006-6 

[ORAUT 2010] reduced the uncertainty factor for the years of 1947 to 1954 to 1.2. The revised 

uncertainty value and technical basis document (TBD) reference will be updated as part of the 

next revision to the DR Template. 
Response Paper Responses to SCA-TR-2019-PR004, Revision 0, Dose Reconstruction 

Template Review for the Peek Street Facility, Schenectady, New York

June 14, 2022

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

FINDING 3

"SC&A was unable to verify the neutron-to-photon ratio of 1.2 using the cited references." 

NIOSH Response:

The basis for the neutron-to-photon (N:P) ratio was developed back in 2009 when the DR 

Template was first created. At that time, the TBDs for the following reactor and critical assembly 

sites were reviewed to determine an appropriate N:P ratio for the PSF: Hanford, Savannah River 

Site, Oak Ridge National Laboratory (ORNL), Idaho National Engineering Laboratory, Los 

Alamos National Laboratory (LANL), Argonne National Laboratory-East, Brookhaven National 

Laboratory, and the Energy Technology Engineering Center. Given that the neutron sources at 

the PSF were only from a critical assembly and/or zero-pile reactor, only the N:P ratios for 

reactors and critical assemblies were considered in the PSF evaluation. 

At ORNL, the N:P ratios for reactors ranged from 0.1:1 to 1:1 (see Attachment C of ORAUT

[2007a]). 

At LANL, the N:P ratios for a critical assembly ranged from 0.67:1 to 1.2:1 for distances of 

5.9 m (19 ft) to 19.8 m (65 ft) (see Table 6-18 in ORAUT [2007b] and ORAUT [2013]). 

Table 6-18 of the LANL TBD also provide N:P ratios at distances beyond 19.8 m, but those 

ratios were extrapolated values versus the measured values. Because neutron exposures beyond 

distances of 19.8 m would have been unlikely for a small facility like the PSF, the extrapolated 

ratios for the farther distances were not used for the PSF evaluation. 

For Hanford, Table 6-22 in ORAUT [2007c] indicated that the geometric means of the N:P ratios 

for reactors were 0.06:1 (N-Reactor) and 0.41:1 (other 100 Area reactors). However, those ratios 

were based on nuclear track emulsion, type A (NTA) film dosimeter data that were later adjusted 

using an assumed adjustment factor to account for the fraction of neutron dose that wasn't 

measured by the dosimeter. Instead of using the N:P ratios based on NTA film results that were 

adjusted with an estimated adjustment factor, the PSF evaluation focused on the measured 

neutron data in Table 6-18. In Table 6-18 of ORAUT [2010], the N:P ratios for the period before

1961 were based on neutron dose measurements rather than NTA film (see Peterson and Smalley 

[1960] for more details). Those measurements were also performed at the front faces to each of 

Hanford's eight production reactors. For the period before 1961 (i.e., before any additional 

shielding was added), the N:P ratios ranged from 0.2:1 to 1.2:1. In addition, N:P ratios based on 

measurements close to the reactor are more representative of the potential exposures at the PSF. 

At the PSF, workers with the potential to receive neutron doses from the source material, critical 

assembly, and/or zero pile were likely within 10 m (33 ft) of the neutron radiation source. 

Based on the information at the time of the PSF DR Template development, the N:P ratios that 

were considered representative ranged from 0.06:1 to 1.2:1. Of those N:P ratios, the 1.2:1 ratio 
Response Paper Responses to SCA-TR-2019-PR004, Revision 0, Dose Reconstruction 

Template Review for the Peek Street Facility, Schenectady, New York

June 14, 2022

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

was selected for the PSF because it resulted in the estimates most favorable to the claimants and 

would ensure that the unmonitored PSF neutron doses were not underestimated. 

Since the development of the PSF DR Template, the N:P ratio information in the external TBD 

for Hanford has changed, and Table 6-18 and its N:P ratio data are no longer in that TBD. 

However, the neutron and photon dose measurement data in Peterson and Smalley [1960] on 

which N:P ratios were based are still considered to be applicable to the PSF. Therefore, NIOSH 

believes the 1.2:1 N:P ratio being used for the PSF is still valid. 

It should also be noted that the N:P ratio is being applied to all photon dosimeter results even 

though neutron exposures at the PSF would have been intermittent. Research reactors and critical 

assemblies only operate intermittently, and neutron exposures were only possible during 

operations. When not being used, neutron generating source material would have been shielded 

for criticality safety reasons. Therefore, not accounting for the intermittent nature of those 

neutron exposures should result in an additional level of favorability to the claimant in the

estimation of neutron dose. 

FINDING 4

"The dosimeter LOD used in the DR Template is not specified in the template, and the value of 

0.050 rem assumed based on NIOSH’s calculation is not consistent with the Hanford dosimeter 

information." 

NIOSH Response:

As noted in the response to Finding 2, the “0.050 rem” value in the DR Template is a placeholder 

value and is designed to be updated during the development of the dose reconstruction. NIOSH 

identified that PSF used a Hanford-type dosimeter throughout its entire operating period. 

Therefore, the dosimeter information from ORAUT [2010], including limits of detection (LOD), 

will be referenced as defaults as part of the next revision to the DR Template. 

FINDING 5

"SC&A was unable to verify the PSF annual maximum ambient dose value using the cited 

reference."

NIOSH Response:

NIOSH identified that an incorrect value of 1.550 rem was originally used for the 1949 ORNL 

dose when the average maximum annual ambient dose value was originally calculated. The 1949 

ORNL dose value should have been 1.555 rem. Correcting that results in an updated average 

value of 0.433 rem, versus the 0.423 rem in the DR Template, which matches SC&A’s 

calculated value. However, NIOSH plans on reevaluating and revising this section with more 
Response Paper Responses to SCA-TR-2019-PR004, Revision 0, Dose Reconstruction 

Template Review for the Peek Street Facility, Schenectady, New York

June 14, 2022

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

current information in order to provide a more accurate estimate of onsite ambient dose as part of 

the next revision to the DR Template. 

FINDING 6

"The DR Template occupational medical dose basis contains incorrect information and outdated 

references."

NIOSH Response:

NIOSH will investigate if occupational medical X-rays for the PSF workers were performed 

offsite. The Occupational Medical Dose Section of the DR Template will be updated based on 

the outcome of this investigation and guidance in ORAUT-OTIB-0006, Dose Reconstruction 

from Occupational Medical X-Ray Procedures [ORAUT 2019] and ORAUT-OTIB-0079, 

Guidance on Assigning Occupational X-ray Dose Under EEOICPA for X-rays Administered Off 

Site [ORAUT 2017]. 

FINDING 7

"The fission product information in the DR Template is not consistent with current guidance in 

ORAUT-OTIB-0054, Revision 04." 

NIOSH Response:

NIOSH agrees that guidance associated with the current version of ORAUT-OTIB-0054, Fission 

and Activation Product Assignment for Internal Dose-related Gross Beta and Gross Gamma 

Analyses [ORAUT 2015], needs to be incorporated into the DR Template. This will be done as 

part of the next revision to the DR Template. 

FINDING 8

"No basis or reference is cited for the recycled uranium activity fractions in Table 5 of the DR 

Template."

NIOSH Response:

NIOSH agrees that the section on the recycled uranium activity fractions should be updated. 

NIOSH will revise the DR Template based on guidance in Battelle-TBD-6000, Site Profiles for 

Atomic Weapons Employers that Worked Uranium Metals [NIOSH 2011]. 
Response Paper Responses to SCA-TR-2019-PR004, Revision 0, Dose Reconstruction 

Template Review for the Peek Street Facility, Schenectady, New York

June 14, 2022

Page 6 of 8 

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

OBSERVATION 1

"SC&A did not locate a PSF-specific tool containing the preprogrammed plutonium DCFs." 

NIOSH Response:

Given the limited number of claims for PSF, no site-specific tool has been created for PSF. For 

sites without a site-specific tool, the complex-wide generic “SM Calculation Workbook” is used. 

OBSERVATION 2

"The natural uranium PSL in the DR Template is not consistent with information in ORAUT 

1997 and is not referenced." 

NIOSH Response:

The color coding in the DR Template indicates that claim-specific PSL values are a placeholder 

value to be updated during the dose reconstruction process. This is why they do not match what 

is in "ORAUT 1997" [GE 1997]. Additionally, "ORAUT 1997" is not the primary reference for 

the PSL values that are used in the PSF dose reconstructions, as the claim-specific information 

takes precedence over generic programmatic information. 

The “5 μg uranium/day” in the template is actually based on the PSLs for natural uranium in 

urine that were reported in Claims [identifying information redacted]. Those [redacted] claims 

were the only known PSF claims with natural uranium urine bioassay data at the time that the 

DR Template was created. Therefore, NIOSH believes that there is value in maintaining the 

“5 μg uranium/day” in the DR Template. 

OBSERVATION 3

"The plutonium composition information is correct. However, the reference cited is outdated and 

needs updating." 

NIOSH Response:

NIOSH agrees that the reference for the plutonium composition information is outdated and 

needs updating. NIOSH will update the reference as part of the next revision to the DR 

Template. 
Response Paper Responses to SCA-TR-2019-PR004, Revision 0, Dose Reconstruction 

Template Review for the Peek Street Facility, Schenectady, New York

June 14, 2022

Page 7 of 8 

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

REFERENCES

GE [1997]. Excerpts from KAPL radiological history report. Peek Street Facility, Schenectady, 

NY: General Electric Company, Knolls Atomic Power Laboratory. December. [SRDB Ref ID: 

34947] 

NIOSH [2011]. Site profiles for atomic weapons employers that worked uranium metals. 

Battelle-TBD-6000, Rev. 1. Cincinnati, OH: U.S. Department of Health and Human Services, 

Centers for Disease Control and Prevention, National Institute of Occupational Safety and 

Health. June 17. [SRDB Ref ID 101251] 

ORAUT [2007a]. Oak Ridge National Laboratory - Occupational external dose. Oak Ridge, TN: 

Oak Ridge Associated Universities Team. ORAUT-TKBS-0012-6 Rev 01, September 10. 

[SRDB Ref ID: 34945] 

ORAUT [2007b]. Los Alamos National Laboratory - Occupational external dose. Oak Ridge, 

TN: Oak Ridge Associated Universities Team. ORAUT-TKBS-0010-6 Rev. 01, May 30 [SRDB 

Ref ID: 32018] 

ORAUT [2007c]. Hanford Site - Occupational external dose. Oak Ridge, TN: Oak Ridge 

Associated Universities Team. ORAUT-TKBS-0006-6 Rev. 03, June 5. [SRDB Ref ID: 32074] 

ORAUT [2010]. Hanford Site - Occupational external dose. Oak Ridge, TN: Oak Ridge 

Associated Universities Team. ORAUT-TKBS-0006-6 Rev. 04, January 7. [SRDB Ref ID: 

77581] 

ORAUT [2013]. Los Alamos National Laboratory - Occupational external dose. Oak Ridge, TN: 

Oak Ridge Associated Universities Team. ORAUT-TKBS-0010-6 Rev. 03, March 21. [SRDB 

Ref ID: 123074] 

ORAUT [2015]. Fission and activation product assignment for internal dose-related gross beta 

and gross gamma analyses. Oak Ridge, TN: Oak Ridge Associated Universities Team. ORAUTOTIB-0054 Rev. 04, August 27. [SRDB Ref ID: 146884] 

ORAUT [2017]. Guidance on assigning occupational X-ray dose under EEOICPA for X-rays 

administered off site. Oak Ridge, TN: Oak Ridge Associated Universities Team. ORAUT-OTIB0079 Rev. 02, June 15. [SRDB Ref ID: 166967] 

ORAUT [2019]. Dose reconstruction from occupational medical X-ray procedures. Oak Ridge, 

TN: Oak Ridge Associated Universities Team. ORAUT-OTIB-0006 Rev. 06, September 27. 

[SRDB Ref ID: 178310] 
Response Paper Responses to SCA-TR-2019-PR004, Revision 0, Dose Reconstruction 

Template Review for the Peek Street Facility, Schenectady, New York

June 14, 2022

Page 8 of 8 

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

 

Peterson EG, Smalley WL [1960]. Proposed procedure for reducing reactor front face dose rates. 

Richland, WA: Hanford Atomic Products Operation. HW-66117, July 19. [SRDB Ref ID: 

15200]